Despite denials from her soon-to-be former employers, the Albright Group, former Clinton EPA head and soon-to-be climate change czar Carol Browner served as a de facto lobbyist for Dubai Ports World, owned by the United Arab Emirate of Dubai, which arranged to buy a company operating six major U.S. ports, including New York and New Jersey.

Browner told the Obama transition team that she never served as a lobbyist in her time in Washington, and her employer, the Albright Group, owned by former secretary of state Madeleine Albright, also said that the firm does not lobby. But in 2006, when the Dubai Ports deal set off a political firestorm, it was Browner taking her clients from Senate office to Senate office looking to build support for the deal.

“She can call what she does whatever she wants, but she was clearly lobbying my boss on the issue,” says a Democrat Senate aide, whose boss ultimately supported the deal. “She was in the room with her clients and the Senator. She pressed him for support. I think that counts as lobbying.”

Browner clearly knew what she was up against, because according to a former Albright Group employee, now working on Obama transition issues at the Department of State, Browner told her Dubai Ports clients that the work to gain support for the port deal was so complicated and controversial that it required an experienced lobbying shop.

She recommended her then-fiancé Tom Downey and his firm, but did not disclose, according to another lobbyist, who worked the Ports deal and is familiar with the situation, her relationship to Downey to the clients. “[Dubai Ports] found out after Downey had been retained. It was an embarrassing situation, but there wasn’t much they could do about it. They were neck deep,” says the lobbyist. Browner continued to work on the deal even after Downey was retained.

Downey represents a number of different clients that will create conflict problems for Browner, many of them in the energy business. Browner, though, won’t have to answer any difficult questions, due to the fact that her White House job is not Senate-confirmable.